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FISCAL YEAR 2014-2015ANNUAL ACTION PLAN

Community Development Block

Grant (CDBG) CDBG Regulations 24 CFR Part 570

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FISCAL YEAR 2013 INCOME LIMIT SUMMARY FOR VENTURA COUNTY

Income Limit Category

1 Person

2 Person

3 Person

4 Person

5 Person

6 Person

7 Person

8 Person

Extremely Low

Income (30%)

$18,350 $21,000 $23,600 $26,200 $28,300 $30,400 $32,500 $34,600

Very Low Income (50%)

$30,600 $35,000 $39,350 $43,700 $47,200 $50,700 $54,200 $57,700

Low Income (80%)

$48,950 $55,950 $62,950 $69,900 $75,500 $81,100 $86,700 $92,300

Median Income $86,700

Source: US Department of Housing and Urban Development December 11, 2012Income Limit areas are based on FY 2013 Fair Market Rent (FMR) areas.http://www.hud.gov/offices/cpd/affordablehousing/programs/home/limits/index.cfm

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CDBG ENTITLEMENT GRANT PROGRAM OBJECTIVES

• The primary objective of the CDBG is to develop viable urban communities by providing decent housing, a suitable living environment, and expanded economic opportunities, principally for persons of low and moderate income.

• The two ways to achieve this objective are: Grantee can only use funds to assist eligible activities meeting

one of the three national objectives (benefiting the extremely low-, very low and low-income persons, prevent and eliminate slums or blight, or meet community development needs having a particular urgency). The activities must be eligible and meet a national objective. (CFR 570.201 to 570.206 Eligible Activities and CFR 570.208 Criteria for National Objectives).

• Grantee must spend 70% of its funds for activities that address the national objective of benefiting low- and moderate-income persons. The following expenditures do not accrue to the 70% expenditure credit: Planning and Administration Slum and blight activities Urgent need activities

CDBG ENTITLEMENT GRANT PROGRAM PARTNERS

• The primary instrument towards achieving the primary objective is to extend and strengthen partnerships amongst all levels of government, private sector and non-profit organizations.

• The CDBG key partners:1. CDBG Grantee2. Subrecipient3. Community-Based Development Organization (CBDO)4. Contractor5. Unit General Local Government

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ELIGIBLE CDBG ACTIVITIES

In general, any activity that is not specifically authorized under the CDBG regulations and statute is ineligible.• 24 CFR 570.201 to 570.206 lists CDBG eligible activities (Attachment

#1)• 24 CFR 570.207 discusses about the ineligible activities (Attachment

#2)

CDBG funds can be used to support public services, affordable housing activities along with other community and economic development activities:• Housing• Other Real Properties• Public Facilities and Improvements• Public Services• Economic Development• Revitalization Areas (NRSA)• Other Eligible Activities

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CDBG NATIONAL OBJECTIVES

Attachment #3 is related to 24 CFR 570.208 criteria for national objectives. Each eligible activity must meet one of the 3 national objectives1. Benefit principally low and moderate income (LMI) persons.

• LMI Area benefit (LMA):• Boundaries of the service area must be primarily residential. The activity should

benefit all the residents in the particular area,• Income data of residents and percent LMI• Commonly used category for community-wide activities• If less than 51 % exception rule applies• Examples of LMA activities are street improvements, neighborhood facilities,

water and sewer lines, and façade improvements in a commercial district that serves a LMI neighborhood

• Limited Clientele (LMC):• Documentation on household size and income of each person receiving the

benefit, in order to show that at least 51%of the clientele are LMI, or • Documentation that facility/service designed for or used exclusively by one of

the eligible “presumptive” groups, or• Documentation of nature and location of the facility/service such that it can be

presumed to service LMI, or• Data showing a special project for accessibility barriers removal.

• LMI Housing (LMH) • The purpose of the eligible activity is to provide or improve permanent

residential structures, that upon completion, will be occupied by low and moderate income households.

• For structures with 3 or more units, low and moderate income households must occupy at 51% of the units

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CDBG - NATIONAL OBJECTIVES CONT’D

• LMI Job (LMJ)• Written agreement with required provisions• Listing of job title of permanent job filled (available to LMI) • Evidence of job lost without CDBG• Listing of job title of permanent jobs retained, including part-time

2. Aid in the prevention and elimination of slums or blight:• Area Slum/Blight:

• Boundaries of the area meeting the definition of slum/blight under the local law;• Description of conditions qualifying the area (substantial number of deteriorated

or deteriorating buildings, or public improvements) and the activity must address one or more of the conditions that contributed to the deterioration of the area;

• Documentation must be maintained on the boundaries and the conditions that qualified the area at the time of its designation.

• Spot Slum/ Blight:• Activities that eliminate specific conditions of blight or physical decay on a spot

basis not located in a designated slum and blighted area.• Only acquisition, clearance, relocation, historic preservation and building

rehabilitation activities qualify for this national objective • Urban Renewal area:

• Activities located within an Urban Renewal project area or Neighborhood Development Program action area that are necessary to complete an Urban Renewal Plan,

• Documentation of the Urban Renewal Plan including maps and supporting documentation must be maintained at the time the CDBG activity is carried on.

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CDBG - NATIONAL OBJECTIVES CONT’D

3. Meet a need with a particular urgency: this category is designated only for activities that alleviate emergency conditions. Urgent need activities must satisfy the following qualifying criteria:

• The existing conditions must pose a serious and immediate threat to the health or welfare of the community; and

• The existing conditions must be of recent origins, or must recently become urgent (last 18 months); and

• The grantee is unable to finance the activity on its own; and• Other sources of funding are not available.

Guide to National Objectives and Eligible Activities for Entitlement Communities

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CDBG - NATIONAL OBJECTIVES CONT’D

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National Objective

s

Low/Mod

LMA

LMC

LMH

LMJ

Slum/Blight

Area Basis

Spot Basis

Urban Renewal

Urgent Needs

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CDBG CAPS

There are 3 categories in CDBG grant:Administration

• Program Administration: overall program management, coordination, monitoring, reporting and evaluation

• Other eligible activities: fair housing activities, indirect costs, citizen participation costs

• 20% of Current Year Allocation and Current Year Program Income FundsPublic Services

• 15% of Current Year Allocation and Prior Year Program Income Funds• The public service must be a new service or a quantifiable increase in the level of a

service• Example of public services include, but are not limited to: child care, health care, job

training, recreation programs, educational programs, public safety services, fair housing activities, services for homeless and for senior citizens, drug abuse counseling and treatment, energy conservation and testing, homebuyer downpayment assistance and welfare (but excluding provisions of income payments)

Capital Improvements Projects (CIP) or Direct Benefits Projects• Housing Activities: housing services, housing rehabilitation, lead-based paint testing

and abatement, and homeownership assistance...• Public Facilities and Improvements: infrastructure, community facilities, special needs

and public facilities• Other Real Property Activities such as Code Enforcement, acquisition, disposition …• Economic Development: Business Technical Assistance, micro-enterprise assistance,

commercial rehabilitation

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CDBG ENTITLEMENT GRANT COMPLIANCE REQUIREMENTS

1. To meet the primary objective of CDBG, grantee is required to expend not less than 70 % of CDBG funds for activities that benefit LMI persons.

2. Under the provisions of 570.902(a), a grantee is considered to be timely, if its rate of expenditure does not exceed 1.5 times the annual current program year grant 60 days prior to the end of the fiscal year. The grantee will be subjected to a reduction of the total amount by which it exceeded the threshold in case of non-compliance. Timely use of funds has been increasingly important in times of tight budget. (Attachment #4 - IDIS PR 56)

3. Environmental review must be complete by the grantee for all project activities prior to obligating CDBG funds. No HUD money may be used to fund projects that cannot receive National Environmental Protection Act (NEPA) clearance. This report must be completed for every CDBG-, HOME- and ESG-funded activity to show that there is no impact on the environment or, if there is, that there is no negative impact on the environment. (24 CFR Part 58)

4. Under certain conditions, the grantee and its subrecipients may incur costs prior to the effective date of the grant agreement with HUD. Pre-award costs should not exceed 25% of grant amount or $300,000, whichever if greater.

PERFORMANCE MEASUREMENT

Performance measurement is an organized process for gathering information to determine how well programs/activities are meeting established needs and goals:• Develop and use a standardized methodology and system to measure the

outcomes of the 4 Community Planning and Development (CPD) formula grant programs: CDBG, HOME, ESG and HOPWA,

• Use a framework by grantee to classify activities in the ConPlan and to report specific required data,

• Enable HUD to report on the outcomes of the 4 grants nationally. The three components of the measurement system are:1. Objectives (3):

• Creating Suitable Living Environments• Providing Decent Housing• Creating Economics Opportunities

2. Outcomes (3):• Availability/Accessibility applies to activities that make services,

infrastructure, public services, public facilities, housing, or shelter• Affordability applies to activities that provide affordability in a variety of

ways to LMI people such as creation and maintenance of affordable housing, basic infrastructure hook-ups, or transportation or day care services.

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PERFORMANCE MEASUREMENT CONT’D

• Sustainability applies to activities aiming at improving communities or neighborhoods, by removing or eliminating slums or blighted areas.

3. Indicators (4):• Amount of leverage from other Federal, state, local and private sources per

activity,• Number of persons, households, businesses, units or beds assisted, as

appropriate,• Income levels of persons or households: extremely low- (30% of AMI), very

low (50% of AMI) and low-income (80% of AMI). For CDBG LMA activities, the data reported will need to show the total number of persons served and the percentage of LMI individuals served.

• Race, ethnicity, and disability data: under CDBG, race/ethnicity data is required only when the undertaken activity benefits directly persons or households such as job creation, housing rehabilitation. This indicator data is not required for activities under CDBG LMA, slum/blight, or urgent need national objectives.

Race: white, Black/African American, Asian, American Indian/Alaskan Native, Native Hawaiian/Other Pacific Islander, American Indian/Alaskan Native & White, Asian White, Black/African American & white, American Indian/Alaskan Native & Black/African, Other multi-racial, Asian/Pacific IslanderEthnicity: Hispanic 14

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REPORTING REQUIREMENTS

• Labor Laws and Requirements: HUD-4710 Form - Semi-annual Labor Standards Enforcement Report

• Minority Business: HUD-2516 Form – Annual Minority Business Enterprise contract and Subcontract Activity

• Section 3: HUD-60002 – Annual Section 3 Hiring and Contracting Summary Report

• Federal Financial Report - SF-425 and SF-425A sent to HUD on a quarterly basis• Quarterly performance updating in IDIS for CDBG activities• Annual Performance Report or Grantee Performance Report (GPR IDIS PR 03)• Consolidated Annual Performance and Evaluation Report (CAPER)

Annual Reports are used to meet 3 basic purposes: Provide HUD with necessary information to assess each grantee’s ability to

carry out its programs in compliance with applicable regulations and requirements,

Provide information necessary for HUD to report to Congress, and Provide grantees with an opportunity to describe its program

achievements with their citizens.

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MONITORING

Monitoring projects is important to any systematic plan of action of managing CDBG (timeliness issue, primary objective, funding criteria for each activity…). Different types of review/monitoring:• Desk review: administrative and financial monitoring• Field Monitoring: project monitoring• HUD Monitoring: program performance monitoring• Corrective Action and Training and Technical Assistance

CDBG- ADMINISTRATIVE REQUIREMENTS

• Labor Standards Requirements: 29 CFR Parts 1, 3, 5, 6 and 7.• Procurement 24 CFR 570.502, 570.610 and 85.36• Environmental Review 24 CFR Part 58• Lead Safe Housing Rule: 24 CFR Part 35, 570.608.• Uniform Relocation Act: 24 CFR Part 42, 49 CFR Part 24 and HUD

Handbook 1378.• Fair Housing and Equal Opportunity Laws: Section 109 and 570.602.

www.hud.gov/offices/fheo/index.cfm• Desk procedure • Program policies and procedures

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CITIZEN PARTICIPATION PLAN

The Oxnard Citizens Participation Plan , originally adopted by the City Council on October 18, 1994, and modified on July 25, 2000, consists of:

• Public Outreach and Access• Public Hearings• Technical Assistance• Comments and complaints• Amendments

24 CFR 91.200(c) and 91.215 (I)

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CONSOLIDATED PLAN AND ANNUAL ACTION PLANS

The consolidated Plan is prepared by the grantee in accordance with 24 CFR Part 91 and describes needs, resources, priorities and proposed activities to be undertaken with respect to HUD’s CPD formula programs (CDBG, HOME, HESG and HOPWA).• June 2013 the City Council approved 2013-2018 Consolidated

Plan and 2013-2014 Action Plan;• HUD approved the submission of the 2013-14 Plan in August

2013; and agreement was executed in September 2013.• FY 2013-2018 Consolidated Plan and FY 2013-14 are posted on

the City website at:http://housing.cityofoxnard.org/Uploads/ConsolidatedPlanFY2013-2018andAnnualActionPlanFY2013-2014DraftSubmitted.pdf

• Information related to the preparation for the 2nd year Annual Action Plan (FY 2014-15) are posted at: http://housing.cityofoxnard.org/10/91

 

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FUNDING PRIORITIES

The Strategic Plan of the Consolidated Plan has established following priority needs and goals:• Housing Need with a high priority level targeting extremely-

low and low-income households and with the goal of assisting the first-time homebuyers to achieve homeownership, creating new affordable rental housing units and housing preservation and maintaining a safe and healthy living environment through code enforcement.

• Homelessness with high priority targeting homeless families with children, chronic homelessness individuals, veterans and victims of domestic violence with the goals of reducing homelessness by providing housing and supportive services, financial assistance (homeless prevention and rapid re-housing to at-risk of becoming homeless persons), job training and placement and shelter services.

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FUNDING PRIORITIES CONT’D

• Non-Housing Community Development with high priority needs, targeting transitional age youth, and low-income at-risk youth with the goals of providing job training and placement, supportive services and recreational services.

• Public Facilities and Improvements needs with high priority level targeting the low- and moderated income areas

• Non-Homeless Special Needs targeting the elderly person, the mentally-ill persons, disabled and substance abused persons by proving housing and supportive services

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HUD FORMULA GRANT PROGRAMS

FIVE YEAR ENTITLEMENT SUMMARY (FY 2010-2014)

2010 2011 2012 2013 2014*

CDBG $2,961,698

$2,472,356

$2,063,138

$2,185,785

$1,967,200

HOME $1,147,134

$1,012,662

$667,268 $646,077 $581,500

ESG $120,297 $187,486 $214,100 $150,512 $135,460

TOTAL $4,229,129

$3,672,504

$2,944,506

$2,982,374

$2,684,160

http://portal.hud.gov/hudportal/HUD?src=/program_offices/comm_planning/about/budget

* Estimated amount only

ANNUAL ACTION PLAN 2014-2015 ALLOCATION

The estimated amount for the program year 2014 is $1,967,2001. Administration maximum amount $393,4402. Public Services maximum amount $295,080. This category

will have a limit for projects funding award ($20,000 minimum and $100,000 maximum).

3. CIP Projects balance $1,278,720.

Adjustments will be done automatically when we will receive PY 2014 HUD allocation.

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EVALUATION CRITERIA

All proposals will be evaluated on specific criteria, including: • Compliance with the CDBG national objectives and the primary

objective;• Eligibility as a CDBG activity;• Ability to receive NEPA clearance;• Overall impact in addressing community needs as identified in

the City’s Consolidated Plan;• Compliance and consistency with local policies, plans and

goals as identified in the City Consolidated Plan;• Financial feasibility and timeliness;• Extended benefit to persons of low and moderate income;• Clarity of the proposal narrative; and • Completeness of the proposalThe due date of the proposal packet is January 24, 2014 at 12 P.M.

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CONSOLIDATED ANNUAL PERFORMANCE AND EVALUATION REPORT (CAPER)

Within 90 days of the end of the fiscal year, a jurisdiction is required to provide an annual report, known as CAPER, to HUD. The CAPER summarizes the City’s performance for the fiscal year and must include a description of the resources made available, the investment of available resources, the geographic distribution and location of investments, the families and persons assisted (including the racial and ethnic status of persons assisted), and other actions indicated in the Strategic Plan and the Action Plan. The grantee should strive to ensure that all applicable deadlines are met and the performance information are accurate. Local jurisdictions that receive CDBG must include the Financial Summary Report (Attachment # 5 - PR26) in addition to the narrative provided in the template.

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INTEGRATED DISBURSEMENT AND INFORMATION SYSTEM (IDIS)

IDIS is the online system for CDBG, HOME, HESG and HOPWA formula grant programs and HOPWA competitive program. IDIS serves 2 major purposes (disbursement and information). Grantees use the system:1. to track the projects/activities and draw down funds and program income, and,2. to record the results of grant funded activities. Grantee Performance Report (Attachment #6 - PR 03), Summary of Accomplishments (Attachment #7 - PR 23) and CDBG Financial Summary Report (Attachment #5 - PR26) are specific to CDBG. HUD uses the data grantees provide in IDIS to report on the performance of the grant programs to Congress and other programs stakeholders.

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PROPOSAL PACKET

1. Project Overview and Information (Attachment #8 – POI)• POI as a funding application form• POI as an IDIS activity data form • POI as a documentation of the environmental

review2. Proposal Narrative3. Itemized Budget

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FY 2014-2015 ANNUAL ACTION PLAN SCHEDULE

Important Dates: • December 10, 2013: FY 2014-15 Needs Assessment public

hearing• March 18, 2014: Second Public Hearing related to priorities

and uses of funds. Mandatory attendance for agencies who have submitted funding applications

• May 6, 2014: 3rd public hearing related to proposed projects to be funded for FY 2014-15 Annual Action Plan

• May 15, 2014: Submission of FY 2014-15 Annual Action Plan to HUD

PROPOSAL AND APPLICATION PROCESS

• January 9, 2014: Pre-Application Sessions. Mandatory workshops for potential applicants.

• January 24, 2014 at 12 PM: Due Date of the proposal packet.

• February 21, 2014 at 12 PM: Due Date of the application packet. If the project is approved by the council to receive CDBG funding, the entire application packet will be part of the agreement.

• March 18, 2014: Public Hearing mandatory attendance for all applicants who have submitted an application packet.

• May 6, 2014: Final Public hearing to adopt the FY 2014-15 Annual Action Plan.

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General Information

Contact information:

William E Wilkins 385-8094 bwilkins@oxnardhousing.org

CDBG Juliette Dang 385-7493 juliette.dang@ci.oxnard.ca.us

HOME Karl Lawson 385-8095 karl.lawson@ci.oxnard.ca.us

ESG Will Reed 385-8044 will.reed@ci.oxnard.ca.us

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QUESTIONS?Written comments are recommended via email contact:

juliette.dang@ci.oxnard.ca.usPhone contacts: Juliette Dang at 805-385-7493 (English)

Angelica Navarro at 805-385-8275 (English/Spanish)

FY 2013-2018 CONSOLIDATED PLANFY 2013-2014 ACTION PLAN